Directed Inquiry

Question: Investigate Clarium Capital: Search SEC EDGAR for "Staff No-Action Letter 2008..2009 investment adviser filing deadline extension". SEC staff no-action letters often formalize temporary relief measures for investment advisers. Report any findings as factual claims with dates and evidence.

Date: 2026-04-08

Research Findings

My investigation did not uncover any SEC staff no-action letter for Clarium Capital regarding investment adviser filing deadline extensions during 2008-2009. The research revealed that Clarium Capital Management LLC was an SEC-registered investment adviser (CRD #138971) that filed regular quarterly Form 13F holdings reports and beneficial ownership disclosures during this period. The firm relocated from San Francisco to New York in 2008 and experienced significant performance challenges, declining 4.5% in 2008 and 25% in 2009. While the SEC's Division of Investment Management issued numerous no-action letters to various investment advisers during the 2008-2009 financial crisis period, particularly regarding money market fund operations and filing deadlines, no specific staff no-action letter for Clarium Capital appears in the public record regarding filing deadline extensions. The absence of such a letter in the comprehensive SEC databases suggests either none was requested or granted, or it may not have been made publicly available if it involved routine administrative matters.

Data Collected

• Entities created: None (all already in database)
• Facts recorded: 2
• Connections mapped: 0
• Web sources consulted: 30

Sources

• sc13gza
• SEC.gov | Division of Investment Management Staff No-Action and Interpretive Letters
• SEC.gov | Division of Investment Management: Modified or Withdrawn Staff Statements
• IAPD - Investment Adviser Public Disclosure - Homepage
• FORM ADV
• SEC.gov | EDGAR Full Text Search
• 2026 Annual and Periodic Reporting & Compliance for Investment Managers | Day Pitney
• Clarium Capital - Wikipedia
• SEC.gov | Information About Registered Investment Advisers and Exempt Reporting Advisers
• SEC FORM D/A
• SEC.gov | Division of Investment Management Staff No-Action and Interpretive Letters
• SEC.gov | Division of Investment Management: Modified or Withdrawn Staff Statements
• SEC.gov | No Action, Interpretive and Exemptive Letters
• SEC.gov | Investment Advisers Act Applications, Notices and Orders
• SEC.gov | Division of Corporation Finance No-Action, Interpretive and Exemptive Letters
• SEC.gov | Staff Responses to Questions About the Custody Rule
• SEC.gov | Staff Letter (No-Action relief under sections 202(a)(30), 203(b)(3), and Rule 202(a)(30)-1 of the Investment Advisers Act of 1940)
• SEC.gov | Investment Management Staff Issues of Interest
• Regulation of Investment Advisers by the
• SEC.gov | Information About Registered Investment Advisers and Exempt Reporting Advisers
• All SEC EDGAR Filings for CLARIUM CAPITAL MANAGEMENT LLC
• Clarium Capital - Wikipedia
• SEC FORM D/A
• sc13gza
• CLARIUM CAPITAL MANAGEMENT LLC (Form: 13F-HR, ...
• Clarium Capital Management Llc 2008 Quarterly Report 13F-HR
• Clarium LP | AUM 13F
• CLARIUM CAPITAL MANAGEMENT LLC
• Richard C. Wilson's Blog : Clarium Capital Management | Peter Thiel San Francisco Hedge Fund | Holdings Analysis
• EDGAR Filing Documents for 0000950123-06-006326